IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

Group-A Autosports, Inc.,
Plaintiff,
v.
J2 Engineering, Inc. and
DNA Motor Inc.,
Defendants.
Civil Action No. : ___________
COMPLAINT
The Plaintiff, Group-A Autosports, Inc., for its Complaint against Defendants, J2
Engineering, Inc. and DNA Motor Inc., alleges as follows:
PARTIES
1. Plaintiff, Group-A Autosports, Inc., is a California corporation having a principal
place of business at 2050 5
th
Street, Norco, CA 92860.
2. On information and belief, Defendant, J2 Engineering, Inc., is a California
corporation having a principal place of business at 5234 E. Pine Avenue, Fresno, CA
93727.
3. On information and belief, Defendant, DNA Motor Inc., is a California
corporation having a principal place of business at 801 S. Sentous Street, City of
Industry, CA 91748.
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JURISDICTION AND VENUE
4. This action arises under the patent laws of the United States, 35 U.S.C. 1 et seq.
5. This Court has subject matter jurisdiction over this dispute pursuant to 28 U.S.C.
1331 and 1338(a).
6. This Court has personal jurisdiction over Defendants based upon theirs contacts
with this forum, including, the sale of infringing products within the Commonwealth of
Massachusetts.
7. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b) and
1400(b).
COUNT I - PATENT INFRINGEMENT - U.S. PATENT NO. D636,316
8. Plaintiff re-alleges each and every allegation set forth in Paragraphs 1-11 as if
fully alleged herein.
9. Plaintiff is the sole owner of U.S. Patent No. D636,316 that issued on April 19,
2011 (the 316 Patent). A copy of the 316 Patent is attached hereto as Exhibit A.
10. The 316 Patent is valid and enforceable.
11. On information and belief, Defendants are making, using, importing, offering for
sale, and/or selling an exhaust header to consumers throughout the United States,
including the Commonwealth of Massachusetts (the Infringing Product).
12. An advertisement for the Infringing Product is shown in Exhibit B attached
hereto.
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13. The Infringing Product was purchased and compared with the claim of the 316
Patent. The Infringing Product is virtually identical to the claimed design of the 316
Patent.
14. Defendants manufacture, import, use, offer for sale, and/or sale of the Infringing
Product infringes the 316 Patent in violation of 35 U.S.C. 271.
15. Defendants infringement of the 316 Patent has caused and continues to cause
Plaintiff irreparable harm.
16. Defendants infringement of the 316 Patent has caused and continues to cause
Plaintiff monetary damage.
REQUESTED RELIEF
Plaintiff requests this Court to enter judgment in favor of Plaintiff against the
Defendants, J2 Engineering, Inc. and DNA Motor Inc, jointly and severally, on the above
counts and grant it the following relief:
1. Pursuant to 35 U.S.C. 283, an Order that Defendants be preliminary
enjoined from making, importing, using, offering for sale, and/or selling the Infringing
Product or any other product that infringes U.S. Patent No. D636,316;
2. Pursuant to 35 U.S.C. 283, an Order that Defendants be permanently
enjoined from making, importing, using, offering for sale, and/or selling the First and
Second Products or any other product that infringes U.S. Patent No. D636,316;
3. Pursuant to 35 U.S.C. 284, that Defendants pay Plaintiff actual damages
as may be proved at trial, and in no event less than a reasonable royalty;
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4. Pursuant to 35 U.S.C. 289, that Defendants pay Plaintiff an amount of
damages equal to the profits realized by Defendants sales of the Infringing Product as
may be proved at trial;
5. Pursuant to 35 U.S.C. 284, that Plaintiff be awarded interest on damages;
6. Pursuant to 35 U.S.C. 284, that Plaintiff be awarded its costs; and
7. Such other relief as this Court deems equitable and just.
REQUEST FOR A JURY
Plaintiff hereby requests a jury on all issues triable by a jury.
Respectfully submitted,
Group-A Autosports, Inc.
By its Attorney,
/s/ Steven N. Fox
Dated: 07-15-2014 Steven N. Fox (BBO #554692)
62 South Main Street
Sharon, MA 02067
(781) 821-8920
E-Mail: sfox@foxpatent.com
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